Modern Slavery Statement 2019/2020 Financial Year 2

Reporting Entity

Over the last 20 years EB Games has become one of Australia’s leading retailers and has grown to more than 420 corporate stores across Australia and under two brand names, EB Games and Zing Pop Culture.

In 2004 EB Games joined the GameStop group which operates more than 5,000 company stores across 10 countries.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year COMPANY FACT SHEET

Electronics Boutique Australia Pty Limited ACN 077 681 442 Entity (‘EB Games’)

GameStop Corp. Ultimate Holding Company (Publicly listed company on the New York Stock Exchange)

Employees + 3,000

Areas of Employment

• Logistics

• Import management

• Refurbishment Distribution Centre /Warehouse of second-hand goods

• Picking and packing

• Forklift and machinery operators

• Customer service • Marketing/Social media

• Store support lines • Website/eCommerce/ • Finance and Accounts Development Store Support Centre (SSC) • Property • Human Resources/Payroll

• Legal • Loss Prevention

• Buying • IT

• Operations managers

• Field managers Field Team • Store managers

• Sales associates

Areas of Operation Australia and New Zealand

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EB ETHOS

Family. Integrity. Our Values Vision. Vitality. Our EB Ethos reflects the heart and soul of EB Games. It defines how we do things, what we Accountability. stand for and what it takes to work here. When we interact with our customers and colleagues the EB Ethos helps us develop and Recognition. grow. Together these values form a culture that we think is unique and sets us apart from the rest.

We are proud of our diverse culture and strive to create an inclusive environment for all employees.

We welcome individuals from diverse backgrounds to be part of the EB Games family.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 6

Our Brands

The retail sale of video and computer equipment, software, digital currency and subscriptions, accessories, games, pop culture items, collectibles, related apparel, and other merchandise.

The retail sale of merchandise related to movies, television shows, the internet, games, books, music and other popular culture mediums including toys, comics, trading cards, clothing, screen media, apparel, board games and other items of a collectable or popular culture nature.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year

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Our Supply Chain

We have large and far reaching supply chains When considering our supply chain, we which is reflected in the diversity of products have looked at a range of aspects within our we bring to the market and the scale of our business, including the supply of: operations. • Physical product sold by our company Over 90% of our annual spend with suppliers is • Manufacturers our business engages with Australian companies. In some instances, to make products on our behalf we are dealing with offices of global companies located in Australia or Australian based • External professional advisors subsidiaries which results in a high percentage • Office suppliers such as stationary, of our cash spend remaining in Australia. cleaners, etc. We acknowledge that in some circumstances • Real estate the product provided by the supplier is not necessarily produced or distributed from their Australian office.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 9

Geographical Location of Suppliers

ISRAEL <1% 0.13% of total suppliers

EUROPE 1.24% of total suppliers

ASIA 1.37% of total suppliers USA / CANADA 2.87% of total suppliers

AUSTRALIA NEW ZEALAND <1% 94.19% of total suppliers 0.20% of total suppliers

Australia Belgium Canada China

France UK Hong Kong Israel Netherlands

New Zealand Singapore United States

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 10

Risks In Supply Chain

We have worked through our organisation as a At EB Games we pride ourselves on the quality whole, reviewing the above areas in our supply of working conditions provided to our staff chain, to separate out the areas where we have across the business and ensure we go above identified potential risks of modern slavery in and beyond to instil a sense of value and our business. This risk has then been split into empowerment. We are constantly ensuring all two categories – employment law requirements are met for our staff in both Australia and New Zealand and • Operational risk are swift to implement any necessary changes • Production and buying risk or updates as required. It is because of this we are proud to confirm Operational Risk the risk of modern slavery from an operational Our operations are based entirely in Australia perspective is very low. and New Zealand. We have been able to Production and Buying Risk undertake a thorough review of potential modern slavery risks in the operational aspects of our Our supply chain with respect to the product organisation because of our domestic location. we sell and manufacture holds the largest area for the opportunity of modern slavery. People are our strength. We recruit and develop a diverse team of high performers and strong When reviewing this specific supply chain in leaders who love winning, embrace change, our organisation we have broken it down into and embody the values of EB Ethos. three main segments (see next page):

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 11

EB Games buys direct from distributor 01 02 EB Games Distributor Zing Pop Culture

• Purchase goods • Arranges manufacturing process • No involvement in • Deals directly with manufacturers manufacturing process/ • Operates as a vendor to design of goods/source EB Games and Zing Pop Culture of primary materials

EB Games engages an agent to deal with manufacturer 01 02 03 EB Games Agent Manufacturer Zing Pop Culture

• Purchase goods • Arranges manufacturing • Sources primary materials • Provide manufacturing process • Manufactures the goods requirements • Deal directly • Employs the factory workers • Accept delivery of goods with manufacturers • Operates as middle party for EB Games and Zing Pop Culture, particularly in cases of language barriers

EB Games engages manufacturer directly 01 02 EB Games Manufacturer Zing Pop Culture

• Purchase goods • Sources primary materials • Provide manufacturing • Manufactures the goods requirements • Employs the factory workers • Arrange manufacturing process • Accept delivery of goods

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 12

Risk Assessment And Due Diligence

EB Games → Distributor In circumstances where we purchase goods endeavour to ensure all vendors/distributors directly from a distributor/vendor EB Games to comply with the GameStop Vendor Product is not involved with the manufacturing process. Quality Terms and Conditions (‘Terms and Conditions’) and the Supplier Code of Conduct Despite not being involved in the manufacturing (‘Code’). process we still require adherence to strict employment standards by the distributor and The Terms and Conditions and the Code sets out the required employment standards, including –

• Child labour

• Forced labour

NO • Harassment or coercion • Bribery

• Fraud

• Discriminate MUST NOT • Restrict freedom of association

• Ensure the Code is communicated to employees, and authorised subcontractor employees (including posting a copy in the local language in a place readily accessible to employees at all times)

MUST • Pay at least minimum wages and provide required benefits and entitlements

• Provide reasonable working hours with days off

• Provide safe and healthy workplaces

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 13

In addition to these requirements, we retain all business dealings with them. the right to conduct periodical audits to For most scenarios where we engage factories ensure their compliance with the Terms and to manufacture products on our behalf we are Conditions and the Code. Failure to comply also partnering with a licensor. with our Terms and Conditions and the Code entitles us to suspend future orders or Where a licensor is involved, we provide terminate any existing purchase orders. a copy of the BSCI audit for the licensor to confirm the accuracy of the audit report and EB Games → Agent → to issue any remediation notices. Once the Factory and EB Games → Factory licensor has approved the manufacturer we When dealing with manufactures, whether proceed with the agreement. through an agent or directly, our company The licensors we partner with hold very high has strict measures in place to ensure we are standards for manufactures and do not waiver minimising our risk of modern slavery. in their requirements. For all manufacturers we work with we require In the rare instances where we are not dealing a Business Social Compliance Initiative (‘BSCI’) with licensed product, we undertake to obtain or similar third party audit to be conducted and the BSCI audit report and conduct a follow up an achievement of a ‘C’ grade or higher in each where remediation is required. category.

Any areas that do not achieve at least a ‘C’ grade compliance are required to be remediated by the next audit. If a manufacturer fails to reach minimum standards by the second audit, we terminate our agreement and cease

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 14

Remediation

EB Games is committed to promoting a culture We also insist on compliance and rectification of ethical behaviour, compliance, and good of deficient areas in BSCI audit reports received corporate governance. from manufacturers and refuse to deal with companies that do not meet our requirements. As part of this EB Games has a Whistleblower Policy accessible to all employees in the company. We are committed to supporting a whistleblower while they raise concerns and protecting them throughout the process.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 15

Assess Effectiveness Of Actions

Our current approach to measuring the effectiveness of our actions includes –

• Continual monitoring of our current systems

• Engagement of external parties to conduct audits

• Reviewing compliance with our Supplier Code of Conduct and Vendor Product Quality Terms and Conditions

• Strong governance

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 16

Consultation

Whilst we do not have any subsidiary companies, we ensure that the practices implemented into our Australian business are mirrored in our New Zealand business.

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year 17

Future Commitments

Over the next financial year, we will focus on –

• Continuing to review and update and processes and procedures currently in place

• Assessing ourselves against the requirements of the Modern Slavery Act 2018 (Cth)

Stephen Charles Wilson Managing Director

Approved by the Board of Directors for Electronics Boutique Australia Pty Limited ACN 077 681 442

MODERN SLAVERY STATEMENT | 2019/2020 Financial Year